428. United Kingdom representatives of non-residents.

A branch or agency1 in the United Kingdom2 through which a non-resident carries on (whether solely or in partnership) any trade, profession or vocation3 is the non-resident's United Kingdom representative in relation to the following amounts4:


    (1)     the amount of any such income from the trade, profession or vocation that arises (directly or indirectly) through or from the branch or agency5;


    (2)     the amount of any income from property or rights which are used by, or held by or for, the branch or agency6;


    (3)     amounts which, by reference to that branch or agency, are chargeable to capital gains